Two major projects for e-invoicing reform get under way in France

Phase 1: Development of the business directory
This centralised directory will collect and organise contact information for businesses receiving e-invoices. It will be populated with information from four sources: the public entity register, France’s National Institute of Statistics and Economic Studies (INSEE) private business database, the register of French VAT taxpayers, and the register of certified PDPs. The directory will then be updated by registered PDPs using addressing information provided by businesses. It will be accessible online and free of charge for businesses.

The business directory will be deployed from February 24, 2025, for a limited number of PDPs. From this date, PDPs can test their ability to receive and update addressing lines for clients they act for as receiving PDPs.

Phase 2: Development of the concentrator
The concentrator will receive, verify, and process directory data for transmission to France’s General Directorate of Public Finances (DGFiP)’s IT system. This data will help establish businesses’ draft VAT returns while supporting future fiscal control strategies. PDPs will be required to send the DGFiP invoicing and transaction data from businesses.  

The pilot phase of the concentrator will open from February 9, 2026. From this date, PDPs can test their ability to send e-reporting and lifecycle data and receive feedback from the concentrator.

Phase 1: Standardising invoice format and content
The DGFiP has announced the creation of a dedicated committee within the Association Française de Normalisation (AFNOR) that will be responsible for developing a national standard of e-invoicing. This standard will be binding on all operators. AFNOR will draft technical documentation covering management rules, lifecycle processes, use cases, and sector-specific requirements, while also participating in EU e-invoicing working groups and initiatives. Documentation produced by AFNOR will replace portions of the external specifications previously managed by France’s public invoicing portal, and will become an enforceable standard for all stakeholders. The first documentation produced by AFNOR is expected to be published by the end of the first half of 2025.

Phase 2: Standardising exchanges between PDPs
Currently, PDPs connect to each other via point-to-point connections. However, this approach can be time-consuming due to the need to sign interoperability agreements and establish individual technical connections between each PDP. It also lacks harmonisation, as each point-to-point connection relies on specific technical settings, complicating management and impeding the fluidity of exchanges. 

The DGFiP has now agreed to be the French authority for Peppol — a standardised framework for electronic document exchange that enables seamless and secure interoperability between parties by using common technical specifications and protocols. Such a network will centralise the governance of interoperability standards, ensuring harmonised exchanges at the national level. Refinements and clarifications will be necessary in early 2025 to enable PDPs to initiate invoice exchanges based on a Peppol architecture tailored to French requirements.

Businesses need to understand the impact of these reforms to effectively prepare for any  transition process. To ensure compliance and readiness, they should focus on the key areas outlined below:

• Business directory — While not initially involved in the technical work, businesses must prepare by defining their addressing lines, specifying how to exchange this information with their PDP, and organising directory access as part of Project 1, Phase 1.
• Concentrator — Businesses must continue analysing e-reporting data requirements, agree with their PDP on exchange formats, and consider early collaboration with their PDP to test the concentrator before the reform’s implementation.
• Standardisation — Active participation in the AFNOR commission is essential to ensure sector-specific requirements are accounted for in the national standard. Interested businesses are encouraged to contact the DGFiP.
• Peppol network — Businesses preparing for the adoption of an established e-invoicing network as a national standard should engage with their PDP, as well as their clients and suppliers, to verify their capability to exchange invoices under new requirements.

The division of France’s e-invoicing program into two structural projects demonstrates the DGFiP and AIFE’s commitment to ensuring a successful implementation while addressing the needs of all stakeholders. However, businesses must actively prepare to integrate these new requirements and anticipate necessary adaptations. This collective mobilisation is critical to ensuring a transition to a harmonised, secure, and efficient invoicing system by project completion in 2026.

Choosing a PDP

With e-invoicing set to become mandatory in France, PDPs will play a crucial role. Businesses operating in France should choose the right PDP solution to stay compliant: accredited PDPs, white-label PDPs, or grey-label PDPs. 

Accredited PDPs

Accredited PDPs are service providers accredited by the DGFiP. Providers must meet strict criteria regarding security, interoperability, and regulatory compliance to gain accreditation, making accredited PDPs the safest choice. 

Accredited PDPs must enable users (as conditions of accreditation) to create, classify, issue, and transmit e-invoices, as well ensure the authenticity of origin, integrity of content, and readability of electronic invoices. They must also transmit invoices to the recipient’s PDP or the public invoicing portal (PPF), ensuring full compliance, and collect and report invoice data to the French tax administration. 

White-label PDPs

White-label PDPs allows ERP providers, invoicing software vendors, and other service providers to offer e-invoicing solutions under their own brand. The final client does therefore not see the PDP provider’s name. White-label PDPs rely on an accredited PDP for compliance, negating the need to go through the PDP accreditation process. 

Grey-label PDPs

In the grey-label PDP model, the client company uses an ERP or invoicing software with integrated PDP options. The ERP provider integrates multiple PDPs into its platform but does not handle registration. The accredited PDP ensures regulatory compliance and invoice processing.

The ERP or software provider does not resell the PDP under its own brand — users can instead choose to activate the integrated PDP or select another one.  

A business’s choice will depend on numerous variables, but a smooth transition to e-invoicing while staying compliant should be the primary goal. As an accredited PDP in France, Avalara can integrate with the ERP systems you already use — including Workday, Oracle, and SAP — so you can maintain business as usual during transitional times and adapt to new rules and requirements as smoothly as possible.

As a registered PDP, Avalara is actively monitoring these developments and working diligently on our PDP implementation to ensure readiness for each milestone of the French mandate. Our teams are committed to supporting businesses throughout this transition, providing the tools and expertise needed to navigate the evolving regulatory landscape with confidence.

Look here for additional information on France’s updates to its e-invoicing reform.

Avalara E-Invoicing and Live Reporting (ELR) can help businesses of all types and sizes adapt to the changing compliance landscape. By integrating with the systems businesses already use, Avalara ELR provides an intuitive e-invoicing solution that users who aren’t tax or tech experts can use to move away from time-consuming and error-prone manual tasks. The cloud-based software updates as more and more mandates and requirements are rolled out and finalised, meaning businesses can scale without disruption and focus on their goals. 

Speak with us today about implementing your e-invoicing solution.